In a significant ruling, the Court of Appeals of Puerto Rico upheld restrictions on short-term rentals in the Rio Mar Village condominium. The decision affects property owners who have been renting their villas for less than 30 days, a practice that has been challenged by the community's governing bodies.
The case, Jorge RodrÃguez Melani et al. v. Consejo De Titulares De Rio Marvillage et al. (Docket No. TA2026AP00213), arose when a group of property owners, including Jorge RodrÃguez Melani and Carlos Fabián Arcaz, appealed a lower court's decision that dismissed their request to declare the condominium's rental restrictions invalid. This ruling is crucial as it clarifies the authority of community governing bodies over property rental practices.
The dispute began when the governing board of Rio Mar Village announced its intention to enforce a long-standing prohibition against rentals of less than 30 days, which had been largely ignored for over two decades. The property owners argued that the board's failure to enforce the rule constituted a waiver of the restriction. They sought a declaratory judgment to lift the prohibition and allow short-term rentals.
The lower court ruled against the property owners, stating that the prohibition was still valid and had not been waived or abandoned. The plaintiffs then appealed the decision, leading to the current ruling by the Court of Appeals.
On May 18, 2026, the Court of Appeals, led by Judge Trigo Ferraiuoli and joined by Judges Candelaria Rosa, Adames Soto, and Campos Pérez, affirmed the lower court's ruling. The court stated, "The prohibition against rentals for less than thirty days remains in effect as per the condominium's governing documents, and the claims of waiver or abandonment by the appellants are not substantiated." This ruling reinforces the authority of the condominium's governing documents and the enforcement of community rules.
The court's decision has significant implications for property owners in Rio Mar Village and potentially sets a precedent for similar cases in other condominiums across Puerto Rico. The ruling emphasizes the importance of adhering to condominium regulations and the legal weight of such restrictions.
Moving forward, property owners in Rio Mar Village must comply with the established rental rules, which may deter short-term rental practices in the area. The ruling also highlights the need for property owners to be aware of and understand the governing documents of their communities, as these documents dictate permissible actions regarding property use.
As for the future of this case, the property owners have the option to appeal the ruling to the Supreme Court of Puerto Rico. However, details on any potential appeal have not been disclosed. The outcome of this case could influence future legal interpretations of condominium regulations and the rights of property owners within such communities.











